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entitled 'Information Security: Improvements Needed in Treasury's
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Report to the Subcommittee on Technology, Information Policy,
Intergovernmental Relations and the Census, Committee on Government
Reform, House of Representatives:
United States General Accounting Office:
GAO:
November 2003:
Information Security:
Improvements Needed in Treasury's Security Management Program:
GAO-04-77:
GAO Highlights:
Highlights of GAO-04-77, a report to the Subcommittee on Technology,
Information Policy, Intergovernmental Relations and the Census, House
Committee on Government Reform
Why GAO Did This Study:
The Department of the Treasury relies heavily on information systems—
and on the public’s trust in its work. Information security is
therefore critical to Treasury operations. In support of its annual
audit of the government’s financial statements, GAO assessed the
effectiveness of (1) Treasury’s information security controls in
protecting the confidentiality, integrity, and availability of the
department’s systems and data and (2) Treasury’s implementation of its
departmentwide information security program.
In assessing the adequacy of Treasury’s information security program,
GAO focused on the effectiveness of its departmentwide policies and
processes, rather than on bureau-specific directives and guidance.
What GAO Found:
The Department of the Treasury and its key bureaus have not
consistently implemented information security controls to protect the
confidentiality, integrity, and availability of their information
systems and data. Several bureaus have reported effective controls
over their systems. However, long-standing information security
weaknesses in access and software change controls, segregation of
duties, and service continuity have been consistently identified at
certain key Treasury bureaus, such as IRS and the Financial Management
Service. Weaknesses at these bureaus place the sensitive information
managed by the bureaus at increased risk of unauthorized access, use,
disclosure, disruption, modification, or destruction. Moreover,
bureaus have not consistently implemented key information security
requirements. An analysis of performance data for the 11 Treasury
bureaus that reported on these requirements for fiscal years 2002 and
2003 reveals that most Treasury systems did not meet certain key
information security requirements in fiscal year 2003 and that the
percentage of systems that meet certain requirements has decreased
from fiscal year 2002 (see chart).
The information security weaknesses and inconsistent implementation of
security controls at Treasury bureaus exist, in part, because
Treasury’s departmentwide security program, while evolving, has not
yet been fully institutionalized across the entire department. During
fiscal year 2003, Treasury launched or expanded several initiatives to
implement key elements of its program. However, additional actions are
needed to effectively and consistently implement information security
controls throughout the department.
What GAO Recommends:
GAO recommends that the Secretary of the Treasury direct the chief
information officer to take specific actions to implement a more
effective departmentwide information security program and improve
management oversight of Treasury’s operating bureaus.
Treasury’s chief information officer, responding on behalf of the
department, concurred with our assessment and recommendations.
www.gao.gov/cgi-bin/getrpt?GAO-04-77.
To view the full product, including the scope and methodology, click
on the link above. For more information, contact Robert F. Dacey at
(202) 512-3317 or daceyr@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Objectives, Scope, and Methodology:
Implementation of Information Security Controls Has Been Inconsistent:
Treasury Has Begun to Implement Key Elements of a Departmentwide
Information Security Program, but Challenges Remain:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendix IComments from the Department of the Treasury:
Related GAO Products:
Table:
Table 1: Analysis of BPD's Prior Year Weaknesses:
Figures:
Figure 1: Percentage of Systems with Risk Assessments during Fiscal
Year 2003:
Figure 2: Percentage of Systems with Up-to-Date Security Plans during
Fiscal Year 2003:
Figure 3: Percentage of Systems Certified and Accredited for Fiscal
Year 2003:
Figure 4: Percentage of Systems with Security Controls Tested in Fiscal
Year 2003:
Figure 5: Percentage of Systems with Tested Contingency Plans:
Figure 6: Percentage of Treasury Systems Meeting Certain Information
Security Requirements:
Abbreviations:
BPD: Bureau of the Public Debt:
CIO: chief information officer:
FISMA: Federal Information Security Management Act:
FMS: Financial Management Service:
GISRA: Government Information Security Reform Act:
IRS: Internal Revenue Service:
NIST: National Institute of Standards and Technology:
OIG: Office of the Inspector General:
OMB: Office of Management and Budget:
POA&M: plan of action and milestones:
TIGTA: Treasury Inspector General for Tax Administration:
United States General Accounting Office:
Washington, DC 20548:
November 14, 2003:
The Honorable Adam H. Putnam:
Chairman:
The Honorable William Lacy Clay, Jr.:
Ranking Minority Member:
Subcommittee on Technology, Information Policy, Intergovernmental
Relations and the Census:
Committee on Government Reform:
House of Representatives:
Information security is a critical consideration for any organization
that depends on information systems and computer networks to carry out
its mission or business. It is especially important for government
agencies, where maintaining the public's trust is essential. Federal
agencies face increasing security risks from viruses, hackers, and
others who seek to disrupt federal operations or obtain sensitive
information stored in federal computers.
The Department of the Treasury, which collects and maintains a
significant amount of sensitive information, needs effective security
controls to prevent the improper disclosure, manipulation, or
destruction of this information. This report presents the results of
our evaluation of the effectiveness of Treasury information security
controls at key bureaus and its implementation of a departmentwide
information security program. In response to your request, we are
addressing this report to you.
Results in Brief:
Treasury and its key bureaus have been inconsistent in implementing
information security controls to protect the confidentiality,
integrity, and availability of their systems and data. Several Treasury
bureaus have reported effective controls that help to secure and
protect their information systems and data. However, long-standing
weaknesses in information security controls (including logical access
controls, physical security, software change controls, segregation of
duties, and service continuity) at key bureaus have reduced these
bureaus' effectiveness in preventing and detecting unauthorized access
to sensitive systems and data, protecting and controlling physical
access to assets, mitigating the risk of unauthorized or inappropriate
software programs, minimizing the risk of errors or fraud, and ensuring
the continuity of data processing operations when unexpected
interruptions occur. In addition, Treasury bureaus have not
consistently performed required information security activities. These
weaknesses expose Treasury to increased risks of unauthorized
disclosure and modification of data and disruption of service that
threaten the confidentiality, integrity, and availability of its
sensitive systems and data.
The information security weaknesses and inconsistent security practices
identified at the bureaus exist, in part, because Treasury's
departmentwide security program, while evolving, is not yet fully
institutionalized across the entire department. Prior to fiscal year
2003, Treasury had not provided adequate direction and oversight to
ensure that the bureaus fully or consistently implemented effective
information security controls. During fiscal year 2003, Treasury
launched or expanded several initiatives that were designed to promote
the implementation of key elements of its departmental information
security program. Although Treasury has made progress implementing
these initiatives, it remains challenged to effectively and
consistently implement security controls across the department. The
effects of a major reorganization on departmental information
technology security staffing, the lack of a designated senior agency
information security official, and issues relating to the reliability
and completeness of performance management data contribute to the
challenges confronting Treasury as it endeavors to improve the security
of its information systems and data. Until Treasury can fully implement
its departmentwide program and adequately mitigate known weaknesses,
increased risk exists that individuals could gain unauthorized access
to critical hardware and software, and intentionally or inadvertently
use, disclose, disrupt, modify, or destroy sensitive data or computer
programs.
We are making recommendations to the Secretary of the Treasury that
address these issues. In providing written comments on a draft of this
report, the Treasury chief information officer responded on behalf of
the department and concurred with our assessment and recommendations,
and provided technical comments that were incorporated into the report
as appropriate.
Background:
The dramatic expansion in computer interconnectivity and the rapid
increase in the use of the Internet are changing the way our
government, the nation, and much of the world communicate and conduct
business. Without proper safeguards, these factors also pose enormous
risks that make it easier for individuals and groups with malicious
intent to intrude into inadequately protected systems and use such
access to obtain sensitive information, commit fraud, disrupt
operations, or launch attacks against other computer systems and
networks.
Protecting the computer systems that support critical operations and
infrastructures has never been more important because of concerns about
attacks from individuals and groups with such malicious intent,
including terrorists. These concerns are well founded for a number of
reasons, including the dramatic increase in reported computer security
incidents, the ease of obtaining and using hacking tools, the steady
advance in the sophistication and effectiveness of attack technology,
and the dire warnings of new and more destructive cyber attacks to
come.
Computer-supported federal operations are likewise at risk. Our
previous reports, and those of agency inspectors general, describe
persistent computer security weaknesses that place a variety of
critical federal operations, including those at Treasury, at risk of
disruption, fraud, and inappropriate disclosure.[Footnote 1] This body
of audit evidence led us, in 1997, to designate computer security as a
governmentwide high-risk area in reports to the Congress.[Footnote 2]
It remains so today.[Footnote 3]
How well federal agencies are addressing these risks is a topic of
increasing interest in both the Congress and the executive branch. This
is evidenced by recent hearings on information security[Footnote 4] and
recent legislation intended to strengthen it--the Federal Information
Security Management Act (FISMA) and the Government Information Security
Reform (GISRA) provisions of the Fiscal Year 2001 National Defense
Authorization Act.[Footnote 5] In addition, the administration has
taken important actions to improve information security, such as
integrating information security into the President's Management Agenda
Scorecard. Moreover, the Office of Management and Budget (OMB) and the
National Institute of Standards and Technology (NIST) have issued
security guidance to agencies.
Treasury Helps Promote the Nation's Economy and Manages Federal
Finances:
The Department of the Treasury is responsible for promoting prosperous
and stable domestic and international economies, managing the
government's finances, and safeguarding federal financial systems.
Treasury is organized into two major components--departmental offices
and operating bureaus. The departmental offices are primarily
responsible for formulating policy and managing the department as a
whole, while the operating bureaus carry out the specific functions of
the department. The basic functions of the department include:
* managing federal finances;
* collecting taxes and monies due to the U.S. and making most of the
payments of the U.S. government;
* producing all postage stamps, currency, and coinage;
* managing government accounts and the public debt;
* supervising national banks and thrift institutions;
* advising on domestic and international financial, monetary, economic,
trade, and tax policy;
* enforcing federal finance and tax laws; and:
* investigating and prosecuting tax evaders.
In fiscal year 2003, Treasury experienced significant organizational
changes. The Homeland Security Act of 2002[Footnote 6] (signed by the
President on November 25, 2002) called for several Treasury bureaus or
elements to be transferred to the newly formed Department of Homeland
Security and to the Department of Justice. On January 24, 2003, the
Bureau of Alcohol, Tobacco, and Firearms' law enforcement function
moved to Justice. The tax and trade functions of the bureau remained
with Treasury under the newly formed Alcohol and Tobacco Tax and Trade
Bureau. On March 1, 2003, three Treasury bureaus moved to Homeland
Security: the Federal Law Enforcement Training Center, the U.S. Customs
Service, and the U.S. Secret Service. The reorganized department had a
fiscal year 2003 budget of $10.7 billion and a staff of about 115,000.
Staff located at the bureaus makes up about 97 percent of the Treasury
work force.
To support the department's overall mission, Treasury and its key
bureaus, including the Internal Revenue Service (IRS)---by far the
largest; Financial Management Service (FMS); U.S. Mint; and the Bureau
of the Public Debt (BPD), have diverse functions. For example, IRS is
responsible for determining, assessing, and collecting internal revenue
in the United States. It collects taxes, processes tax returns, and
enforces the nation's tax laws. In fiscal year 2003, IRS processed
about 130 million[Footnote 7] individual tax returns, accounted for
almost $2 trillion in collections, and paid about $300 billion in
refunds to taxpayers. FMS receives and disburses public monies,
maintains government accounts, and prepares reports on the status of
government finances. As the government's financial manager, FMS
disbursed more than $1.6 trillion in fiscal year 2003. BPD borrows the
money needed to finance the federal government and administers the
public debt through Treasury financial instruments. It is responsible
for ensuring that reliable systems and processes are in place for
purchasing and servicing Treasury securities. In fiscal year 2003, BPD
conducted about 200 auctions and issued about $4 trillion in marketable
securities.
Treasury and its bureaus rely heavily on information management systems
to fulfill their many financial management stewardship roles and
responsibilities for the nation. The bureaus have distinct, numerous,
and complex information systems to process, store, and secure highly
sensitive data. Treasury and its bureaus report in fiscal year 2003
that they have 708 distinct information systems supporting their
operations. A centralized data communications network and management
system interconnects networks and systems at the bureaus and
departmental offices.
FISMA provides that the Secretary of the Treasury is responsible for,
among other things, (1) providing information security protections
commensurate with the risk and magnitude of the harm resulting from
unauthorized access, use, disclosure, disruption, modification, or
destruction of the agency's information systems and information; (2)
ensuring that senior agency officials provide information security for
the information and information systems that support the operations and
assets under their control; and (3) delegating to the agency chief
information officer (CIO) the authority to ensure compliance with the
requirements imposed on the agency under the act. Treasury's CIO is
responsible for developing and maintaining a departmentwide information
security program; developing and maintaining information security
policies, procedures, and control techniques that address all
applicable requirements; and assisting senior agency officials
concerning their responsibilities under the act. In addition, the CIO
provides oversight, strategic management, and policy direction on all
information security programs within Treasury. The Office of Security
Compliance within the Office of the CIO is responsible for developing
departmentwide information security policies and ensuring bureau
implementation. Each bureau is responsible for implementing Treasury-
mandated security policies within its domain. In order to implement
departmentwide security policies, the bureaus are required to develop
their own information security programs, including their own security
compliance functions.
Objectives, Scope, and Methodology:
Our objectives were to (1) determine whether Treasury and its key
bureaus have effectively implemented information security controls to
protect the confidentiality, integrity, and availability of their
systems and data and (2) determine whether Treasury has effectively
implemented its departmentwide information security program.
To determine the effectiveness of the information security controls
implemented at Treasury and its bureaus, we considered the results of
prior information security reviews that we performed at IRS, BPD, and
FMS. We also examined and analyzed the contents of audit reports and
associated work papers for information security and internal
control[Footnote 8] reviews performed by the Treasury Office of the
Inspector General (OIG) or independent auditors in connection with
their audits of the bureaus' financial statements. In addition, we
reviewed the department's performance and accountability reports to
document Treasury's information security-related weaknesses.
To assess Treasury's departmentwide information security program, we:
* reviewed and evaluated the department's information security policies
in effect at the time of our review;
* analyzed data presented in Treasury's GISRA report for fiscal year
2002 and FISMA report for fiscal year 2003;[Footnote 9]
* examined and assessed reports and other documents related to the
department's information security program, and:
* interviewed Treasury officials regarding their processes and
procedures for overseeing, monitoring, evaluating, and reporting on the
implementation of information security across the department.
Our review was performed at Treasury headquarters and our headquarters
in Washington, D.C., from March through October 2003, in accordance
with generally accepted government auditing standards.
Implementation of Information Security Controls Has Been Inconsistent:
The effective implementation of appropriate, properly designed security
controls is an essential element for ensuring the confidentiality,
integrity, and availability of information systems and information.
Weak security controls can expose information systems and information
to an increased risk of unauthorized access, use, disclosure,
disruption, modification, and destruction.
Treasury's bureaus have not consistently implemented effective
information security programs and resolved known information security
control weaknesses. Some bureaus have consistently reported
implementing effective controls over their information systems and/or
limiting the negative effect control weaknesses could have on the
preparation of financial statements and internal controls. Other key
Treasury bureaus, including IRS and FMS, have reported long-standing
weaknesses in information security controls and continued to report
significant weaknesses in fiscal year 2002. As a result of the
weaknesses and inconsistencies in the overall implementation of the
bureaus' information security programs, the Treasury OIG designated
information security as a departmentwide material weakness[Footnote 10]
in its fiscal year 2002 financial audit report.
Several Bureaus Have Effectively Implemented Controls:
Several Treasury bureaus have consistently implemented effective
information security controls over their computing environments and/or
implemented compensating controls to correct or mitigate the weaknesses
identified during previous audits. For example, the external auditors
for the Office of Thrift Supervision, the Office of the Comptroller of
the Currency, and the Bureau of Engraving and Printing have not
reported significant information security control weaknesses. BPD has
also consistently implemented internal control over its financial
systems. Since 1997 we have reviewed the general and application
controls over key BPD systems as part of our audit of the Schedule of
Federal Debt managed by BPD. We found that, although security over its
computer systems and service continuity controls needed strengthening,
BPD maintained, in all material respects, effective internal control,
including general and application computer controls, related to
reporting reliable financial information on the Schedule of Federal
Debt.
In instances in which information security improvements were needed,
BPD management has been responsive in taking corrective action or in
implementing compensating controls to mitigate the weaknesses
identified during our reviews. As the following table indicates, our
subsequent audits have found that, as of May 2003, BPD had taken action
to correct or mitigate a substantial percentage of the security
weaknesses reported during the prior year's audit.
Table 1: Analysis of BPD's Prior Year Weaknesses:
Fiscal year audited: 2002; Weaknesses from prior year: 17; Weaknesses
resolved: Number: 12; Weaknesses resolved: Percentage: 71.
Fiscal year audited: 2001; Weaknesses from prior year: 13; Weaknesses
resolved: Number: 8; Weaknesses resolved: Percentage: 62.
Fiscal year audited: 2000; Weaknesses from prior year: 17; Weaknesses
resolved: Number: 16; Weaknesses resolved: Percentage: 94.
Fiscal year audited: Total/Average; Weaknesses from prior year: 47;
Weaknesses resolved: Number: 36; Weaknesses resolved: Percentage: 77.
Source: GAO.
[End of table]
Key Bureaus Have Ineffective Security Controls:
Strengthening information systems controls at other bureaus is one of
the management challenges currently facing the Department of the
Treasury. In fiscal year 2002, significant information security
weaknesses existed in the computer systems used at key Treasury bureaus
to process sensitive information and data needed to accomplish
Treasury's mission. Weaknesses span all six general control audit areas
addressed in our information security audit methodology.[Footnote 11]
These six areas are (1) security program management, which provides the
framework for ensuring that risks are understood and that effective
controls are selected and properly implemented; (2) access controls,
which ensure that only authorized individuals can read, alter, or
delete data; (3) software development and change controls, which ensure
that only authorized software programs are implemented; (4) segregation
of duties, which reduces the risk that one individual can independently
perform inappropriate actions without detection; (5) operating systems
controls, which protect sensitive programs that support multiple
applications from tampering and misuse; and (6) service continuity,
which ensures that computer-dependent operations experience no
significant disruptions. We identified information systems security as
a major challenge for Treasury in our 2003 performance and
accountability report on the department.[Footnote 12] The following
examples highlight the serious information security weaknesses that
existed at Treasury's key bureaus.
Internal Revenue Service:
Since 1992,[Footnote 13] we have reviewed the effectiveness of IRS
information security in connection with our annual audit of IRS's
financial statements and conducted information security reviews over
IRS's computing facilities and electronic filing systems at the request
of the Congress. The results of these reviews have led us each year to
designate information security as a material weakness. During the 3-
year period ending July 31, 2002, we conducted 14 information security
reviews at 11 IRS tax processing facilities nationwide. These reviews
identified 765 specific general control weaknesses and demonstrate the
departmentwide challenge IRS and Treasury face in addressing
information security. In addition, we conducted 5 application control
reviews and reported 112 application control weaknesses during this
same period. While the majority of general control weaknesses
identified fell in the area of logical access controls, weaknesses in
physical security, software change controls, segregation of duties, and
service continuity also posed significant risk to IRS systems and
taxpayer information, as the following illustrates:
* Inadequate logical access controls diminished the reliability of
IRS's computerized data and increased the risk of unauthorized
disclosure, modification, and use of sensitive systems and taxpayer
data. Logical access controls at IRS facilities did not effectively
prevent, limit, or detect access to computing resources. IRS did not
adequately control user accounts and passwords to ensure that only
authorized individuals were allowed access to computer systems.
Inactive and unused user system accounts were found at all 11 IRS
computing facilities reviewed. In addition, IRS inappropriately granted
powerful operating system privileges to users who did not need them and
granted users access to certain system files for which they had no
business need. Further, inadequate controls over network services and
devices were found that could allow intruders to gain unauthorized
access to valuable information about IRS systems without logging on to
the systems.
* Physical security control weaknesses, such as inadequate physical
barriers and ineffective screening of visitors, contributed to
weakening the perimeter security at several IRS facilities. As a
result, increased risk exists that individuals could gain unauthorized
access to facility grounds, buildings, sensitive computing resources,
and taxpayer data, without detection.
* Software change control procedures at two facilities did not provide
sufficient control mechanisms to ensure that the facilities received
all authorized program updates. In addition, software developer
accounts and/or development tools were allowed on production servers at
five facilities, which increases the risk that individuals could make
unauthorized modifications to production software on these servers.
* Inadequate segregation of duties was also an issue, as IRS did not
consistently separate incompatible computer-related activities among
individuals performing system administration and security
administration duties at its computing facilities. In addition, IRS
assigned incompatible operating system privileges to users, such as
granting auditing privileges to system administrators at 10 facilities.
As a result, increased risk exists that erroneous or unauthorized
activity could occur and go undetected.
* Service continuity control weaknesses limited IRS's ability to
restore and continue critical data processing services in the event of
unexpected service interruptions. IRS had not developed disaster
recovery plans for certain key systems and/or had not adequately tested
service continuity plans at several facilities. As a result, increased
risk exists that IRS will not be able to protect or recover essential
information and critical business processes in the event of an
unexpected interruption of service.
IRS has made progress in correcting the general and application control
weaknesses identified in our information security reviews during this
3-year period. In May 2003 we reported that IRS had corrected about
one-third of the 765 general control weaknesses and 55 percent of the
application control weaknesses identified in our reviews.[Footnote 14]
Although IRS has corrected a significant number of weaknesses, many
significant weaknesses in information security controls remain.
Financial Management Service:
FMS has experienced long-standing weaknesses in its computer controls.
It has reported its overall information systems security environment as
a material weakness every year since fiscal year 1998. Treasury has
recognized the seriousness of this problem and reported FMS's computer
controls as a material weakness in its annual accountability reports
for each of those fiscal years. In January 2002, we reported that FMS's
overall information security control environment was ineffective in
identifying, deterring, and responding promptly to computer control
weaknesses.[Footnote 15] In November 2002, the independent external
auditor responsible for auditing FMS's fiscal year 2001 and 2002
financial statements reported a material weakness in the general
controls over the Hyattsville (Md.) Regional Operations Center. The
external auditor reported that general controls did not effectively
prevent (1) unauthorized access to the disclosure of sensitive
information, (2) unauthorized changes to systems and application
software, (3) unauthorized access to programs and files that control
computer hardware and secure applications, or (4) disruption of
critical operations. Specifically, the external auditor found
weaknesses in the following areas:
* Access controls. The majority of information security weaknesses were
identified in this area. Weaknesses were found in the administration of
access controls, access to computer programs and files, and access to
sensitive data.
* Systems software. The development and enforcement of systems software
policies and procedures over usage and modifications to operating
system upgrades and utilities were inadequate.
* Change controls. Configuration change management control procedures
were not consistently enforced across all major FMS applications
reviewed.
* Service continuity. Although FMS has completed its business impact
assessment,[Footnote 16] the results of this assessment had not been
incorporated into detailed disaster recovery plans.
Although the independent external auditor reported that FMS had made
improvements in its information security control environment during
fiscal year 2002, the external auditor was critical of the overall
effectiveness of FMS's information security management program. FMS
management was still in the process of implementing its new entitywide
security plan--authorized in September 2002--for most of the year under
audit. While FMS has corrected vulnerabilities in some areas,
subsequent reviews have found that previously identified weaknesses
continue to exist on other systems.
U.S. Mint:
Significant information security weaknesses also existed at the U.S.
Mint. The independent external auditor responsible for auditing the
Mint's fiscal year 2001 financial statements identified numerous
general and application control weaknesses. Due to the magnitude of
these weaknesses, the external auditor reported two separate material
weaknesses--one for general controls and one for application controls.
In its audit report on the Mint's fiscal year 2002 financial
statements, the external auditor aggregated the two previously reported
material weaknesses into one material weakness on information systems
controls. The auditor noted that the Mint had made improvements in its
computer control environment and systems security control activities,
which included the development of a comprehensive corrective action
plan, and hired a new chief information officer. However, the external
auditor noted weaknesses in the Mint's information systems general
controls relating to its network infrastructure, systems documentation,
software change control, and related security policies and procedures.
Bureaus Have Not Consistently Performed Required Information Security
Activities:
Assessing and managing the risks associated with information systems
are key elements of an information security program. FISMA[Footnote 17]
and other federal guidance[Footnote 18] require federal agencies to
develop comprehensive information security programs based on assessing
and managing risks. OMB requires agencies to report performance measure
data related to required aspects of their information security
programs. These data include the number and percentage of systems that
have:
* been assessed for risk and assigned a level of risk,
* up-to-date security plans,
* been certified and accredited,
* security controls that have been tested/evaluated within the last
year,
* contingency plans, and:
* tested contingency plans.
Treasury also requires that its bureaus use these same performance
measures when reporting to it on the status of bureau information
security programs. Performance data reported by the bureaus indicate
that the bureaus have not consistently performed these required
information security activities and that certain bureaus performed them
better than others. For example, bureaus reported that the percentage
of systems that they performed these required activities ranged from 0
to 100 percent of their systems.
Many Systems Do Not Have Risk Assessments:
Risk management is a process that allows information technology
managers to balance the operational and economic costs of protective
measures to achieve gains in mission capability by protecting the
information technology systems and data that support organizational
missions. Agencies, including Treasury, are required to perform
periodic threat-based risk assessments for systems and data. Risk
assessments are an essential element of risk management and overall
security program management and, as our best practice work has shown,
are an integral part of the management processes of leading
organizations.[Footnote 19] Risk assessments help ensure that the
greatest risks have been identified and addressed, increase the
understanding of risk, and provide support for needed controls.
Treasury bureaus have not consistently assessed their systems for risk.
According to Treasury's FISMA report for 2003 and as illustrated in
figure 1, four bureaus reported that they had assessed risk for 90 to
100 percent of their systems. However, figure 1 also shows that the
other nine bureaus, including the four that reported that less than
half of their systems had been assessed for risk, did not consistently
assess risks for their systems.
Figure 1: Percentage of Systems with Risk Assessments during Fiscal
Year 2003:
[See PDF for image]
[End of figure]
The bureaus also experienced mixed results in fiscal year 2003 with
increasing the percentage of their systems that have been assessed for
risk. Of the 11 bureaus that reported this security metric in both
fiscal years, 4 reported an increase in the percentage of systems
assessed for risk in fiscal year 2003 compared with fiscal year 2002,
while 4 reported a decrease. The remaining 3 bureaus did not report a
change in the percentage of systems assessed for risk.
Systems Often Lack Up-to-Date Security Plans:
OMB Circular A-130 requires that security plans be prepared for all
federal systems that contain sensitive information. The purpose of
these plans is to (1) provide an overview of the security requirements
of the system and describe the controls in place or planned for meeting
those requirements, (2) delineate the responsibilities and expected
behavior of all individuals who access the system, and (3) serve as
documentation of the structured process of planning adequate, cost-
effective security protection for a system.
Treasury bureaus did not consistently maintain up-to-date security
plans for their systems. According to Treasury's FISMA report for 2003,
only 304 (43 percent) of the department's 708 systems had up-to-date
security plans. Although IRS had by far the largest number of systems
without a security plan, 8 of the 13 bureaus reported that they had up-
to-date security plans for less than 90 percent of their systems for
fiscal year 2003, as shown in figure 2.
Figure 2: Percentage of Systems with Up-to-Date Security Plans during
Fiscal Year 2003:
[See PDF for image]
[End of figure]
Bureaus Have Not Certified and Accredited Many Systems:
OMB and Treasury require management officials to formally authorize the
use of each general support system and major application through a
certification and accreditation process before it becomes operational,
when a significant change occurs, and at least every 3 years
thereafter. System certification is based on a technical evaluation of
an information system to see how well it meets its security
requirements, including all applicable federal laws, policies,
regulations, and standards. System accreditation is the written
management authorization for a system to operate and/or process
information.
Treasury bureaus did not certify and accredit many of their systems.
According to Treasury's FISMA report for fiscal year 2003 and as shown
in figure 3, 11 of 13 bureaus reported that less than 90 percent of
their systems had been certified and accredited for fiscal year 2003.
Moreover, 2 bureaus reported that none of their systems had been
authorized for processing following system certification and
accreditation.
Figure 3: Percentage of Systems Certified and Accredited for Fiscal
Year 2003:
[See PDF for image]
[End of figure]
Our analysis of data submitted by the 11 bureaus that reported on this
performance measure for both fiscal years 2002 and 2003 showed mixed
progress. For example, 5 of the 11 bureaus reported a decrease in the
percentage of systems authorized for processing following certification
and accreditation, while 5 of the remaining 6 bureaus showed
improvement in this area.
Bureaus Are Not Routinely Testing and Evaluating Security Controls:
An agency head is responsible for ensuring that the appropriate agency
officials evaluate the effectiveness of the information security
program, including testing controls. Further, the agencywide
information security program is to include periodic management testing
and evaluation of the effectiveness of information security policies
and procedures. Periodically evaluating the effectiveness of security
policies and controls and acting to address any identified weaknesses
are fundamental activities that allow an organization to manage its
information security risks cost-effectively, rather than reacting to
individual problems ad hoc only after a violation has been detected or
an audit finding has been reported. Further, management control testing
and evaluation as part of the program reviews can supplement control
testing and evaluation in IG and our audits to help provide a more
complete picture of the agency's security posture. FISMA requires that
agencies test the management, operational, and technical controls of
every information system identified in their inventories of major
information systems no less than annually.
Most Treasury bureaus did not test the security controls on each of
their inventoried systems during fiscal year 2003. As illustrated
below, 9 of the 13 Treasury bureaus reported in Treasury's FISMA report
that they had tested the controls on less than 90 percent of their
systems for fiscal year 2003, including 6 that tested controls on less
than half of their systems.
Figure 4: Percentage of Systems with Security Controls Tested in Fiscal
Year 2003:
[See PDF for image]
[End of figure]
Bureaus Have Not Consistently Prepared or Tested Contingency Plans:
Contingency plans provide specific instructions for restoring critical
systems, including such items as arrangements for alternative
processing facilities, in case the usual facilities are significantly
damaged or cannot be accessed.
These plans and procedures help to ensure that critical operations can
continue when unexpected events occur, such as a temporary power
failure, an accidental loss of files, or a major disaster. Contingency
plans should also identify which operations and supporting resources
are critical and need to be restored first and should be tested to
identify their weaknesses. Without such tested plans, agencies have
inadequate assurance that they can recover operational capability in a
timely, orderly manner after a disruptive attack.
Treasury bureaus have not consistently prepared or tested contingency
plans for their information systems. According to Treasury's FISMA
report for fiscal year 2003, only 44 percent of its systems had a
contingency plan. Bureaus also reported that 41 percent of their
systems had tested contingency plans. As shown in figure 5, only 2 of
13 bureaus reported that they had tested contingency plans for at least
90 percent of their systems. Moreover, 4 bureaus reported that none of
their contingency plans had been tested.
Figure 5: Percentage of Systems with Tested Contingency Plans:
[See PDF for image]
[End of figure]
The bureaus' inconsistent track record for performing these essential
information security activities can lead to the implementation of
insecure systems and/or the implementation of inadequate or
inappropriate security controls that do not sufficiently address
threats to these systems and could result in costly efforts to
subsequently implement effective controls.
Treasury Has Begun to Implement Key Elements of a Departmentwide
Information Security Program, but Challenges Remain:
The information security weaknesses and inconsistent security practices
identified at the bureaus exist, in part, because Treasury's
departmentwide security program, while evolving, is not yet fully
institutionalized across the entire department. At Treasury, the vast
majority of the department's information system assets and computing
operations are located at the operating bureaus. Each bureau has been
assigned responsibility for developing and maintaining an effective
information security program for managing its information security
risks, in accordance with departmental policies. Although
responsibility for developing and maintaining an effective bureau-
specific information security program has been delegated to each
operating bureau, broad program responsibility for information security
throughout the department is assigned to the Treasury CIO. However,
prior to fiscal year 2003, Treasury had not provided adequate direction
to or oversight of the bureaus to ensure that key elements of a strong
information security program were fully and consistently implemented at
each bureau, as the following examples illustrate.
* Treasury's information security policies and procedures were outdated
and incomplete. The principal policy document governing Treasury's
information security program was Treasury Directive 71-10, Department
of Treasury Security Manual. The primary purpose of this document was
to establish comprehensive, uniform security policies, procedures, and
guidelines that were to be followed by each bureau in developing its
own specific policies and operating directives. However, the security
manual contained policies that had not been revised since 1992 and did
not reflect current federal guidance. For example, the manual was
silent in many areas where security policy was needed, such as voice
mail, e-mail, and security-incident reporting. In addition, Treasury's
security manual did not provide to the bureaus policies or guidance in
the areas of virus protection, audit trails, and warning banners.
Although most bureaus have developed their own information security
policies, five relied exclusively on these outdated and incomplete
policies to implement their information security programs.
* Treasury had not established effective processes and procedures for
monitoring and overseeing the implementation of security at the
bureaus. The Office of Security Compliance within the Office of
Treasury CIO is responsible for monitoring Treasury bureaus and
ensuring compliance with federal and Treasury security policies.
However, prior to fiscal year 2002, the office did not conduct security
reviews of bureau information security programs. In fiscal year 2002,
the office conducted 35 security reviews of the bureaus' information
systems and programs. According to Treasury officials, these reviews
were limited in scope, were conducted only at selected bureaus, and did
not represent a complete security program review. For example, some
security reviews consisted primarily of reviewing a system's security
plan and did not include testing security controls for the system.
Treasury Is Implementing Elements of an Information Security Program:
To address these issues and improve oversight of information security
at the bureaus, Treasury launched or expanded several initiatives
during fiscal year 2003 that were designed to promote the
implementation of key elements of a departmentwide information security
program.
* Appointment of chief information officer. In March 2003, Treasury
appointed a new departmental CIO. FISMA provides that the authority to
ensure compliance with the requirements imposed on the agency under the
act be delegated to the agency CIO. The CIO's responsibilities include
developing and maintaining a departmentwide information security
program and security policies and providing oversight, strategic
management, and policy direction on all information security programs
within Treasury.
* Development of information security governance model. The Treasury
CIO proposed a governance model for information security during fiscal
year 2003. Elements of the model include integrating security programs
both functionally with capital planning and organizationally across
bureaus; increasing CIO oversight; increasing bureau self-assessments;
creating and distributing comprehensive security policies, standards,
and procedures; establishing a security policy forum; and linking the
information technology governance process to the enterprise
architecture and capital investment and planning process.
* Updated departmental information security policies and procedures.
During fiscal year 2003, Treasury undertook a major revision of its
outdated and incomplete information security policies. In August 2003,
Treasury published a comprehensive, up-to-date body of information
security policies and procedures--the Treasury Information Systems
Security Program--consisting of the Treasury Information Technology
Security Program Policy (Volume 1) and the Treasury Information
Technology Security Program Handbook (Volume 2). The documents replaced
Treasury Directive 71-10 and formally establish a uniform baseline for
the department's information security requirements. They are based on
requirements levied by the FISMA, NIST, and OMB and are to serve as a
framework for the bureaus as they develop their specific policies and
operating directives.
* Expanded program and system review. Treasury expanded its review of
the bureaus' information security programs and systems during fiscal
year 2003. According to Treasury's fiscal year 2003 FISMA report, one
departmental initiative to create and maintain a system inventory
revealed an additional 270 systems in fiscal year 2003. The department
also conducted reviews of each bureau's information security program
and performed 21 system certification and accreditation package
reviews. In addition, Treasury conducted vulnerability scans on
networks and performed system penetration tests as part of its program
and system reviews.
* Analysis of bureaus' plans of action and milestones. Treasury
continued tracking and analyzing the plan of action and milestones
(POA&M) reported by the bureaus on a quarterly basis. This plan is a
tool that details the tasks that need to be accomplished and the
resources required, milestones, and scheduled completion dates for
accomplishing the tasks. The purpose of a POA&M is to help agencies
identify, assess, prioritize, and monitor the progress of corrective
efforts for security weaknesses found in programs and systems. OMB
requires agencies to (1) develop a separate POA&M for every program and
system for which weaknesses were identified and (2) report quarterly on
progress implementing the plans. Accordingly, Treasury requires its
bureaus to maintain POA&Ms on all information security weaknesses and
provide quarterly updates to the Treasury CIO's office. Treasury
monitors bureau progress in correcting weaknesses by using the plans as
a performance tracking mechanism. According to the Treasury CIO,
Treasury analyzes the updated plans for quality and completeness and
evaluates progress and other significant trends that may influence the
resolution of security-related weaknesses.
* Educational outreach programs. According to Treasury's FISMA report
for fiscal year 2003, Treasury's oversight and compliance program also
developed and maintained a series of outreach programs that are
designed to educate Treasury employees about elements of information
security compliance and to stimulate dialogue among security
practitioners and stakeholders across the department.
* Increased funding for information technology security. According to
Treasury's FISMA report for fiscal year 2003, the department more than
doubled its total information security spending, from $85 million in
fiscal year 2002 to $174 million in fiscal year 2003.
Despite Initiatives, Information Security Challenges Remain:
Although Treasury has significantly increased funding for information
security and has begun to make progress implementing key elements of
its information security program, it remains challenged to effectively
and consistently implement security controls and procedures across the
department. As illustrated in figure 6, an analysis of security metric
data in Treasury's fiscal year 2002 GISRA report and its fiscal year
2003 FISMA report[Footnote 20] shows that:
* the majority of Treasury systems do not meet key information security
requirements, and:
* Treasury's reported performance in meeting certain of these
requirements has decreased.
Figure 6: Percentage of Treasury Systems Meeting Certain Information
Security Requirements:
[See PDF for image]
Note: This chart reflects data for the 11 Treasury bureaus that
reported on these security requirements for both years.
[End of figure]
Treasury reported that it did not implement any of these six required
information security activities on a majority of its systems for fiscal
year 2003. For example, Treasury established a specific goal that 80
percent of all information systems be certified and accredited by the
end of fiscal year 2003. However, as of August 15, 2003--the date of
data contained in its FISMA report for fiscal year 2003--Treasury had
certified and accredited only about 24 percent of its 708 systems.
According to Treasury's CIO, this was due to (1) the discovery of 276
additional systems at the IRS as a result of an effort to compile an
accurate inventory and (2) a new reporting requirement that stipulated
that systems with an interim authority to operate not be counted in
fiscal year 2003 as an accredited system. In fiscal year 2002, such
systems were counted as accredited for reporting purposes.
In addition, implementation of certain information security
requirements has decreased from fiscal year 2002. For the 11 bureaus
that reported performance measures for both years, the percentage of
Treasury systems implementing five of the six requirements decreased in
fiscal year 2003, while it increased for one. For example, Treasury-
reported data for fiscal year 2002 shows that 93 percent of the systems
at those bureaus were assessed for risk and assigned a level of risk,
while for fiscal year 2003 only 42 percent were.
Treasury's overall performance demonstrates that it continues to face
challenges implementing and monitoring information security throughout
the department. The following factors contribute to the challenges
confronting Treasury as it endeavors to improve the security of its
information systems and data:
* Treasury reorganization. Throughout fiscal year 2003, Treasury
underwent a major reorganization. The reorganization resulted in the
reassignment of three bureaus to the Department of Homeland Security,
the creation of a new entity within Treasury, and the transfer of about
50 percent of Treasury's information technology security staff to the
Department of Homeland Security. The reduction in staff resulting from
the reorganization, combined with the reported increase in the total
number of departmental systems, could hinder the department's ability
to provide effective oversight and direction over the bureaus'
information security programs.
* Senior information security officer has not been designated. FISMA
requires that a senior agency information security officer be
designated to carry out the information security duties and
responsibilities of the CIO under the act. This senior level official
is to (1) have information security as his or her primary duty; (2)
head an office with the mission and resources necessary to assist in
ensuring compliance with the act; and (3) possess the professional
qualifications, including training and experience, required to
administer the functions described in the act. The official would
oversee the development and implementation of departmental information
policies, procedures, and control techniques and coordinate
departmentwide security-related activities to ensure that weaknesses
identified in one bureau's systems do not place the entire department's
information assets at undue risk. However, Treasury has not designated
a senior agency information security officer to develop, maintain, and
oversee the department's security program. The lack of a senior
information security officer with the stature and experience as well as
the responsibility and authority for directing and overseeing the
implementation of the departmentwide program could impair departmental
control or influence in information security program decisions made by
the bureaus.
* Reliability and completeness of performance information. Although
FISMA reporting provided performance information on key security areas,
it is important for agencies to ensure that they have the appropriate
management structures and processes in place to strategically manage
information security, as well as to ensure the reliability of
performance information. For example, disciplined processes can
routinely provide the agency with timely, accurate, and useful
information for day-to-day management of information security. Treasury
has established a process for receiving quarterly updates on the
bureaus' plans of actions and milestones and issuing an annual data
call to the bureaus for performance information on key information
security requirements used in FISMA reports. However, the Treasury
reports reveal issues with the reliability and completeness of bureau-
reported information. For example, in Treasury's fiscal year 2002 GISRA
report, there were significant differences between what Treasury and
the OIG reported for the percentage of systems that met certain
information security requirements.
* In addition, the Treasury Inspector General for Tax Administration
(TIGTA) states in the fiscal year 2003 FISMA report that IRS's POA&Ms
do not report on the status of system-specific vulnerabilities and are
not specific enough to ensure accountability and timely remediation of
the vulnerabilities. TIGTA also states that since IRS's POA&Ms are not
reported by system, justifications for information security funding
found in its business cases cannot be tied to or linked with weaknesses
reported in the POA&M. With the need for effective oversight to ensure
compliance with the departmentwide information security program and the
need to comply with a new requirement by OMB for quarterly reporting of
agency progress against certain information security performance
measures, disciplined processes that can routinely provide Treasury
with timely, accurate, and useful information for day-to-day management
of information security will become more important for the department.
Conclusions:
Weaknesses in information security controls at Treasury bureaus have
placed its financial and information management systems at risk and
could hinder its ability to effectively and efficiently accomplish its
mission. Although Treasury has taken the initial steps necessary to
implement a departmentwide information security program, key elements
of such a program--those needed to help mitigate Treasury's long-
standing information security weaknesses--have not been fully
implemented. Implementing an effective information security program
could help ensure that known weaknesses affecting Treasury's computing
resources are promptly mitigated and that general controls effectively
protect its computing environments. Until Treasury oversees the
implementation of a departmentwide security program, limited assurance
exists that it and its bureaus will be able to resolve known
information security weaknesses and adequately safeguard their
information resources.
Recommendations for Executive Action:
To improve oversight and compliance with Treasury's information
security program, we recommend that the Secretary of the Treasury
direct the chief information officer to do the following:
* Assess the staffing and resource requirements for performing the
department's oversight and compliance efforts to ensure that
departmental information security policies are effectively and
consistently implemented throughout the organization.
* Designate a senior agency information security officer.
* Examine existing reporting processes and implement procedures to
enhance the reliability and completeness of the bureau-provided
information required for day-to-day management of information security.
Agency Comments:
In providing written comments on a draft of this report (which are
reprinted as appendix 1), the Treasury CIO responded on behalf of the
department and concurred with our assessment and recommendations. In
addition, the CIO underscored his commitment to implementing a new
security governance model that not only aligns with Treasury's
information technology governance model but also aligns with security
policies and security operations. The Treasury CIO also provided
technical comments that have been incorporated into the report as
appropriate.
If you have any questions or need further information, please contact
Gregory C. Wilshusen, Assistant Director, at (202) 512-6244, or me at
(202) 512-3317. We can also be reached by e-mail at wilshuseng@gao.gov
and daceyr@gao.gov, respectively. Kenneth A. Johnson and Ronald E.
Parker made key contributions to this report.
Robert F. Dacey:
Director, Information Security Issues:
Signed by Robert F. Dacey:
[End of section]
Appendix I: Comments from the Department of the Treasury:
DEPARTMENT OF THE TREASURY:
WASHINGTON, D.C. 20220:
November 7, 2003:
Mr. Robert F. Dacey Director:
Information Security Issues:
General Accounting Office:
441 G Street, NW,
Rm 5T37 Washington, DC 20548:
Dear Bob:
Thank you for the opportunity to review and to comment on your draft
report entitled "Information Security: Improvements Needed in
Treasury's Security Management Program" (Report #GAO-04-77). I concur
with the GAO's assessment and its recommendation; attached please find
comments that may provide additional clarification.
Please note the following on C&A: the Department has stressed to the
bureaus they need to identify and to report an accurate inventory of
systems. In FY 2003, the Department obtained from each bureau a
complete register of general support systems and major applications.
Through diligent work conducted by each bureau and the Department IT
Security Program, Treasury now has a truer - but higher - number of
systems based on FISMA requirements. While we endorse moving the "bar"
to its correct position means Treasury's percentage of systems C&A'd
decreases, the benefits to our security objectives should be
emphasized.
Finally, I want to underscore my commitment to implementing a new
security governance model that not only aligns with our overall IT
governance model (affecting how we allocate IT funds across Treasury)
but also aligns security policies and security operations - a critical
issue that, once properly addressed, will accelerate progress. Ensuring
that the Department is not only promulgating policies but also
enforcing policies across the bureaus with sufficient resources is
essential to securing the Treasury Department.
If you have any questions regarding our comments, please contact me at
202 622-1200 or via email at drew.ladner@do.treas.gov.
Thank you for your assistance.
Sincerely,
Signed by:
Drew Ladner:
Chief Information Officer:
Attachment:
[End of section]
Related GAO Products:
Information Security: Computer Controls Over Key Treasury Internet
Payment System. GAO-03-837. Washington, D.C.: July 30, 2003.
Information Security: Progress Made, but Weaknesses at the Internal
Revenue Service Continue to Pose Risks. GAO-03-44. Washington, D.C.:
May 30, 2003.
Bureau of the Public Debt: Areas for Improvement in Computer Controls.
GAO-03-524R. Washington, D.C.: May 1, 2003.
Information Security: Progress Made, But Challenges Remain to Protect
Federal Systems and the Nation's Critical Infrastructures. GAO-03-564T.
Washington, D.C.: Apr. 8, 2003.
High-Risk Series: Protecting Information Systems Supporting the Federal
Government and the Nation's Critical Infrastructures. GAO-03-121.
Washington, D.C.: January 2003.
Major Management Challenges and Program Risks: Department of the
Treasury. GAO-03-109. Washington, D.C.: January 2003.
Computer Security: Progress Made, But Critical Federal Operations and
Assets Remain at Risk. Washington, D.C.: GAO-03-303T. Nov. 19, 2002.
Financial Audit: IRS's Fiscal Years 2002 and 2001 Financial Statements.
GAO-03-243. Washington, D.C.: Nov. 15, 2002.
Financial Audit: Bureau of the Public Debt's Fiscal Years 2002 and 2001
Schedules of Federal Debt. GAO-03-199. Washington, D.C.: Nov. 1, 2002.
Bureau of the Public Debt: Areas for Improvement in Computer Controls.
GAO-02-1082R. Washington, D.C.: Sept. 18, 2002.
Information Security: Comments on the Proposed Federal Information
Security Management Act of 2002. GAO-02-677T. Washington, D.C.: May 2,
2002.
Information Security: Additional Actions Needed to Implement Reform
Legislation. GAO-02-470T. Washington, D.C.: Mar. 6, 2002.
Financial Audit: IRS's Fiscal Years 2001 and 2000 Financial Statements.
GAO-02-414. Washington, D.C.: Feb. 27, 2002.
Financial Audit: Bureau of the Public Debt's Fiscal Years 2001 and 2000
Schedules of Federal Debt. GAO-02-354. Washington, D.C.: Feb. 15, 2002.
Financial Management Service: Significant Weaknesses in Computer
Controls Continue. GAO-02-317. Washington, D.C.: Jan. 31, 2002.
Computer Security: Improvements Needed to Reduce Risk to Critical
Federal Operations and Assets. GAO-02-231T. Washington, D.C.: Nov. 9,
2001.
Bureau of the Public Debt: Areas for Improvement in Computer Controls.
GAO-01-1131R. Washington, D.C.: Sept. 13, 2001.
Management Letter: Improvements Needed in IRS's Accounting Procedures
and Internal Controls. GAO-01-880R. Washington, D.C.: July 30, 2001.
Computer Security: Weaknesses Continue to Place Critical Federal
Operations and Assets at Risk. GAO-01-600T. Washington, D.C.: Apr. 5,
2001.
Internal Revenue Service: Progress Continues But Serious Management
Challenges Remain. GAO-01-562T. Washington, D.C.: Apr. 2, 2001.
Financial Audit: Bureau of the Public Debt's Fiscal Years 2000 and 1999
Schedule of Federal Debt. GAO-01-389. Washington, D.C.: Mar. 1, 2001.
Financial Audit: IRS' Fiscal Year 2000 Financial Statements. GAO-01-
394. Washington, D.C.: Mar. 1, 2001.
Information Security: IRS Electronic Filing System. GAO-01-306.
Washington, D.C.: Feb. 16, 2001.
Computer Security: Critical Federal Operations and Assets Remain at
Risk. GAO/AIMD-00-314. Washington, D.C.: Sept. 11, 2000.
Information Security: Serious and Widespread Weaknesses Persist at
Federal Agencies. GAO/AIMD-00-295. Washington, D.C.: Sept. 6, 2000.
Information Security: Software Change Controls at the Department of
Treasury. GAO/AIMD-00-200R. Washington, D.C.: June 30, 2000.
Management Letter: Suggested Improvements in IRS's Accounting
Procedures and Internal Controls. AIMD-00-162R. Washington, D.C.: June
14, 2000.
Financial Audit: IRS's Fiscal Year 1999 Financial Statements. AIMD-00-
76. Washington, D.C.: Feb. 29, 2000.
Federal Information System Controls Audit Manual. GAO/AIMD-12.19.6.
Washington, D.C.: January 1999.
Organizations Information Security Management: Learning from Leading.
GAO/AIMD-98-68. Washington, D.C.: May 1998.
High-Risk Series: Information Management and Technology. GAO/HR-97-9.
Washington, D.C.: February 1997.
Financial Audit: Examination of IRS's Fiscal Year 1992 Financial
Statements. GAO/AIMD-93-2. Washington, D.C.: June 30, 1993.
FOOTNOTES
[1] U.S. General Accounting Office, Information Security: Serious and
Widespread Weaknesses Persist at Federal Agencies, GAO/AIMD-00-295
(Washington, D.C.: Sept. 6, 2000).
[2] U.S. General Accounting Office, High-Risk Series: Information
Management and Technology, GAO/HR-97-9 (Washington, D.C.: February
1997).
[3] U.S. General Accounting Office, High-Risk Series: Protecting
Information Systems Supporting the Federal Government and the Nation's
Critical Infrastructures, GAO-03-121 (Washington, D.C.: January 2003).
[4] U.S. General Accounting Office, Information Security: Continued
Efforts Needed to Fully Implement Statutory Requirements, GAO-03-852T
(Washington, D.C.: June 24, 2003); Information Security: Progress Made,
But Challenges Remain to Protect Federal Systems and the Nation's
Critical Infrastructures, GAO-03-564T (Washington, D.C.: Apr. 8, 2003);
Computer Security: Progress Made, But Critical Federal Operations and
Assets Remain at Risk, GAO-03-303T (Washington, D.C.: Nov. 19, 2002).
[5] Federal Information Security Management Act (FISMA), Title III,
Public Law 107-347, Dec. 17, 2002, and the Government Information
Security Reform provisions (commonly referred to as GISRA) of the
Fiscal Year 2001 National Defense Authorization Act, Division A, Title
X, Subtitle G, Public Law 106-398, Oct. 30, 2000.
[6] Public Law 107-296.
[7] As of August 31, 2003.
[8] A review of an entity's internal controls includes a review of the
information security controls--general controls and application
controls--that protect an organization's computer environment.
[9] GISRA expired Nov. 29, 2002. Effective Dec. 17, 2002, FISMA
replaced GISRA with similar, but strengthened, provisions.
[10] A material weakness is a condition that precludes the agency's
internal controls from providing reasonable assurance that material
misstatements in the financial statements would be prevented or
detected on a timely basis.
[11] U.S. General Accounting Office, Federal Information System
Controls Audit Manual, GAO/AIMD-12.19.6 (Washington, D.C.: January
1999).
[12] U. S General Accounting Office, Major Management Challenges and
Program Risks: Department of the Treasury, GAO-03-109 (Washington,
D.C.: January 2003).
[13] U.S. General Accounting Office, Financial Audit: Examination of
IRS's Fiscal Year 1992 Financial Statements, GAO/AIMD-93-2 (Washington,
D.C.: June 30, 1993).
[14] U.S. General Accounting Office, Information Security: Progress
Made, but Weaknesses at the Internal Revenue Service Continue to Pose
Risks, GAO-03-44 (Washington, D.C.: May 30, 2003).
[15] U.S. General Accounting Office, Financial Management Service:
Significant Weaknesses in Computer Controls Continue, GAO-02-317
(Washington, D.C.: Jan. 31, 2002).
[16] FMS's business continuity planning activities have been split into
two phases: conducting a business impact assessment and preparing
detailed recovery plans.
[17] Public Law 107-347, section 301(2002); 44 USC 3544(b).
[18] The February 1996 revision to OMB Circular A-130, Appendix III,
Security of Federal Automated Information Resources, directs agencies
to use a risk-based approach to determine adequate security, including
a consideration of the major factors in risk management: the value of
the system or application, threats, vulnerabilities, and the
effectiveness of current or proposed safeguards.
[19] GAO/AIMD-98-68.
[20] IRS management indicated that controls in additional systems were
tested subsequent to the effective date of Treasury's FISMA report.
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